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Pennsylvania: $99,000 Settlement for 22 Years in Solitary Confinement

A Pennsylvania federal district court held that general issues of material fact required a jury to determine whether a prisoner’s Eighth and Fourteenth Amendment rights were violated when he was held in solitary confinement for over 22 years. Before going to trial, however, the case settled for just under $100,000 plus certain concessions from prison officials.

Before the district court were cross motions for summary judgment. The parties agreed on only two things: that Pennsylvania state prisoner and former Black Panther Russell “Maroon” Shoatz had been held in continuous solitary confinement from June 1991 until February 2014, and that he had a history that included violence and escapes.

Shoatz was convicted of first-degree murder for his role in an attack on a Philadelphia police guardhouse in 1970 that left one officer dead and another wounded, for which he received a life sentence. In 1977, Shoatz and three other prisoners escaped from SCI Huntingdon, injuring several guards. One prisoner was killed and Shoatz was captured a month later.

While on the lam he entered a prison guard’s home; he forced the guard and his family to drive to a wooded location where he left them tied to trees. After his capture, he was convicted of escape, robbery, kidnapping and simple assault. Diagnosed with paranoid-schizophrenia, he was admitted to a hospital for the criminally insane but escaped in 1979, taking a hostage and using guns that had been smuggled in to him.

Those facts led to Shoatz’s return to prison and placement in solitary confinement after he was caught in 1980. He was transferred to the general population in 1982, but again put in segregation the following year. He was sent to USP Leavenworth in 1989 and placed in general population without incident. When returned to Pennsylvania’s prison system in June 1991, however, he was returned to solitary confinement, where he remained until 2014.

While in segregation in the Restricted Housing Unit (RHU), Shoatz was confined to a 7’ x 12’ cell where the lights remained on constantly. He was allowed out for one hour a day, five days a week in a recreation cage, which required a strip search. He was moved to a different cell every 30 to 90 days. As a result of these conditions his mental health deteriorated significantly, according to Dr. James Gilligan, an expert witness in Shoatz’s lawsuit. The mental health problems that Shoatz developed included “years of chronic depression, bouts of suicidal ideation, high levels of anxiety, severe difficulty concentrating, short term memory loss, fear of leaving his cell, depression, emotional numbing, and an inability to form intimate relationships.”

The district court found Shoatz’s claims were not barred by the statute of limitations, as he alleged his placement in segregation was a “continuing practice.” It also found he had adequately exhausted his administrative remedies. Having disposed of those initial procedural matters, the court turned to the constitutional issues.

As to the Eighth Amendment claim, “Shoatz has produced sufficient evidence for a reasonable fact finder to determine that the cumulative effect of over 22 years in consecutive solitary confinement constitutes a sufficiently serious deprivation of at least one basic human need, including sleep, exercise, social contact, and environmental stimulation,” the court wrote. “It is obvious that being housed in isolation in a tiny cell for 23 hours a day for over two decades results in serious deprivations of basic human needs.”

The district court also found the defendants were aware of the general risks inherent in prolonged solitary confinement, and specifically aware of Shoatz’s situation. The court noted that “a conclusion ... that prolonged isolation from social and environmental stimulation increases the risk of development of mental illness does not strike this court as rocket science.”

Shoatz had been placed on the Restricted Release List (RRL), a way to designate certain prisoners for indefinite solitary confinement, when it was first implemented in 2004. The court held a jury needed to decide whether Shoatz received all the process he was due while on the RRL. It also found the defendants were not entitled to qualified immunity, and Shoatz could pursue injunctive relief even though he had since been transferred to a different prison.

The parties’ cross motions for summary judgment were denied on February 12, 2016, and the case was set for trial. However, a settlement was reached in June 2016 that required the defendants to pay $99,000 in damages, inclusive of attorney fees. Additionally, the defendants agreed to provide Shoatz with single cell status “for the duration of his confinement with the Department of Corrections”; to not put him in the RHU based solely on his past disciplinary record or conduct; to make their “best efforts” to notify his attorneys if he is returned to the RHU; and to provide him with a mental health evaluation and mental health services that are “commensurate with the mental health stability rating” determined by the evaluation.

Shoatz was ably represented by attorneys Ben Grote and Dustin McDaniel with the Abolitionist Law Center; Richard L. Etter and Stefanie Lepore Burt with the law firm of Reed Smith, LLP; Daniel M. Kovalik with the United Steelworkers of America; and Harold J. Engel. See: Shoatz v. Wetzel, U.S.D.C. (W.D. Pa.), Case No. 2:13-cv-00657-CRE; 2016 U.S. Dist. LEXIS 17515.

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Related legal case

Shoatz v. Wetzel